1991 Utah L. Rev. 93 (1991)
Molko v. Holy Spirit Association for the Unification of World Christianity: Does the First Amendment's Free Exercise Clause Protect Cultic Recruitment and Indoctrination Tactics

handle is hein.journals/utahlr1991 and id is 103 raw text is: Molko v. Holy Spirit Association for the
Unification of World Christianity: Does the First
Amendment's Free Exercise Clause Protect Cultic
Recruitment and Indoctrination Tactics?
I. INTRODUCTION
Suppose you are standing on a city street corner waiting for a
bus when a seemingly friendly fellow-traveler strikes up a conver-
sation with you. After a few minutes of casual talking, the discus-
sion becomes more serious and you discover that the stranger has
social, j olitical or environmental concerns similar to your own. In
what appears to be a spontaneous gesture of friendship, your new
acquaintance invites you to join her and other like-minded individ-
uals for dinner and a discussion of issues of mutual concern. You
hesitate to accept the invitation and ask whether the group has
some religious connection. The woman assures you that the group
has no religious affiliation.
You accept the invitation to the gathering. After dinner, you
and other dinner guests attend a lecture on social problems and
watch a slide show of a farm located a few hours away that the
group describes as a rural getaway. You and the other guests are
invited to visit the farm that night. Enchanted by everyone's
friendliness and hospitality, you go. Twelve days later, you are still
at the farm, exhausted and confused, when you learn that the rural
getaway is actually an indoctrination camp operated by the Unifi-
cation Church.1 What has happened? Could you have been sub-
jected to some form of religious indoctrination without your knowl-
edge? You are bewildered and disoriented. You have been duped
by Church members who assured you that the group had no reli-
gious connection. Do you have any legal remedy against the reli-
gious group for its deception?
On facts virtually identical to the foregoing, the California Su-
preme Court answered that question in the affirmative in Molko v.
Holy Spirit Association for the Unification of World Christian-
1. The Unification Church refers to the Holy Spirit Association for the Unification
of World Christianity, the controversial religious organization founded by Korean industri-
alist Sun Myung Moon. Throughout this Note, the organization is referred to as either the
Unification Church or simply the Church.

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